Reporting requirements for refrigeration industry companies

Growing interest in environmental protection prompts more frequent reflection on human activities that contribute to its degradation. Air pollution is linked to industrial development and occurs as a result of the introduction into the atmosphere of solid, liquid or gaseous substances in quantities that may adversely affect human health, climate, nature, soil or water, or cause other environmental damage. Atmospheric pollution is a problem on a global scale, so combating it has become one of the more important tasks of international organisations. Global solutions for air protection are essential because of the virtually unrestricted mobility of pollutants. This fact, together with growing public awareness of the need for environmental protection, necessitates international cooperation on monitoring and protecting the atmosphere. Poland’s membership of the European Union and the associated need to align national legislation with Community recommendations and standards is expanding the Polish legal system in this area. The main instruments used to promote pro-environmental measures are legal and economic instruments. In the legislative sphere, regulations are introduced above all governing the rules for monitoring and limiting pollution (emission limits). Economic factors motivating reduction of pollutant emissions include taxes, duties and penalties, but also various preferences such as tax reliefs or co-funding. Entities operating in the refrigeration industry should therefore not disregard environmental protection issues and should familiarise themselves with the regulations and the consequences of non-compliance with applicable legal acts. The specific properties of fluorinated greenhouse gases, and above all their high refrigerating efficiency, make them well suited to refrigeration applications; nevertheless, efforts are made to limit their use because of their high global warming potential (GWP), which reflects their adverse impact if released into the atmosphere. Production and use of the above refrigerants have grown steadily in recent years. The consequence is an increase in emissions of greenhouse gases contributing to global climate warming. Requirements related to limiting emissions of environmentally harmful refrigerants are set out in the so-called F-gas Act. Under the applicable regulations, operators of equipment containing at least 5 tonnes of CO2 equivalent of fluorinated greenhouse gases or 3 kg of controlled substances are obliged to register them in the Central Operators Register (CRO).

Table 1. CRO registration criterion for selected refrigerants

The Act emphasises measures preventing emission of the described substances into the environment, inter alia by imposing an obligation of periodic leak checks of refrigeration and air-conditioning equipment, heat pumps and refrigerating units. The criterion for mandatory checking is the quantity of refrigerant contained in the installation - the so-called charge - converted, in the case of F-gases, into the equivalent quantity of carbon dioxide.

Table 2. Criteria for mandatory leak checks in accordance with Regulation (EU) No 517/2014:

*The leak detection system must be checked every 12 months to ensure its proper functioning.

Example protocol of a periodic leak check

Figure 1. Specimen labelling of equipment that has successfully passed a unit leak check in accordance with EU Reg. No 517/2014

Entities operating in the industry are furthermore obliged, depending on the type of activity, to submit the following annual reports:

• report on fluorinated greenhouse gases (F-gases) and ozone-depleting substances (ODS). This obligation applies to entities importing, exporting, using, recovering, recycling, reclaiming or destroying F-gases and ODS on the territory of the Republic of Poland. Records must be kept in electronic form via the BDS system (Report Database)
• reports on use of the environment and payment of fees to the Marshal’s Office (including for the introduction of gases or dusts into the air resulting from equipment operation). In accordance with the Act of 27 April 2001 – Environmental Protection Law (Journal of Laws of 2017, item 519), an entity using the environment is obliged to prepare
• reports on emissions of greenhouse gases and other substances (in accordance with the Act of 17 July 2009 on the system for managing emissions of greenhouse gases and other substances (Journal of Laws of 2013, item 1107) to the database of the National Centre for Emissions Balancing and Management (KOBiZE)

Tracking changes in applicable environmental regulations is time-consuming and their interpretation is difficult. The resulting obligations are a considerable challenge, especially for small entities operating in the refrigeration and air-conditioning industry. The Central Refrigeration Centre “COCH” in Kraków, responding to client demand, has launched the following services:

• Keeping a refrigerant balance and assistance in preparing mandatory reports on fluorinated greenhouse gases (F-gases) and ozone-depleting substances (ODS) to BDS, the Marshal’s Office and KOBiZE
• CRO system support (registration in the system, creating and maintaining Equipment Cards)
• Periodic leak checking of refrigeration equipment in accordance with the requirements of Commission Regulation (EU) No 517/2014
• Assistance in preparing procedures required by the Office of Technical Inspection (UDT) for company certification
• Training for operators of refrigeration equipment and mobile units,
• F-gas training – covering stationary equipment, mobile units, automotive air conditioning and other specialist training in refrigeration, air conditioning and heat pumps

Mandatory reports prepared by users and service technicians, equipment records, leak checks - these are among many obligations imposed by the regulations. Ignorance of legal acts does not exempt from the obligation to comply with them. To avoid getting lost in the maze of obligations, contact our specialists, who will be happy to help you.

Author: MSc Eng. Klaudia Paszkowska